Yesterday the SEC staff issued CD&I 105.09, which clarifies the date by which issuers must comply with the new requirement to present changes in stockholders' equity in their interim financial statements. Initially, there was concern that the requirement would be effective shortly before many companies would ordinarily file their Forms 10-Q for the quarter ending on September 30. The new CD&I clarifies that the staff will not object if issuers comply with the new requirement for the first quarter that begins after the effective date of the new rule, which will likely happen in October. Calendar year issuers should present the new disclosures in their quarterly reports for the quarter ending March 31, 2019.
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